​A recent decision by the Court of Appeal in South Australia offers a significant message to local governments managing remote and rural coastlines. The case of Gregory Warren v District Council of Lower Eyre Peninsula (2025) underscored that while signage and barriers are valuable safety tools, their effectiveness and reasonableness depend heavily on location, visitor frequency, and resource availability.

The incident involved a teenager who fell approximately 10 metres from a cliff at a remote beach on the Eyre Peninsula back in 2013. The individual sued the council, claiming it had failed in its duty of care by not installing warning signs or barriers along the coastline. The District Court dismissed the claim, and the Court of Appeal recently upheld that decision, affirming that the council's decision not to erect signage was reasonable.

In this instance, the court recognised that the location was infrequently visited (about 50 kilometres north of Coffin Bay, accessible only via an unformed road, and designated as 'wilderness coastline'). The limited foot traffic meant that installing signs or barriers would have equated to unnecessary expenditure. The court acknowledged that in such remote areas, the cost of signage may outweigh the safety benefits, and that the risk of injury was relatively low due to the natural features and the infrequent visitation.

However, it is important for members not to become complacent, as the court's ruling would have certainly been different had the incident occurred in a busier, tourist-prone area. In locations with high foot traffic, signage and barriers are not just advisable, they are expected.

Local governments in these areas should proactively install clear, visible signage and barriers to warn visitors of hazards, as the courts would likely view such measures as a reasonable and necessary part of risk management.

Overall, the case is a win for the sector, affirming that responsible risk management involves making contextually appropriate decisions. It highlights that signage is a powerful safety tool, but only when used where it makes sense.

For more information we encourage members to contact our LGIS risk services team or your regional risk specialist.